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License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. December 21, 2011 | License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. December 21, 2011 | ||
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--------------x DECLARATION OF KATHRYN M. LIBERATORE Pursuant to 28 U.S.C. § 1746, Kathryn M. Li beratore hereby declares as follows: | --------------x DECLARATION OF KATHRYN M. LIBERATORE Pursuant to 28 U.S.C. § 1746, Kathryn M. Li beratore hereby declares as follows: | ||
: 1. I serve as an Assistant A ttorney General for the State of New York, counsel for petitioner-intervenor State of New York in this proceeding. I submit this declaration and accompanying exhibits in support of the Stat e of New York's contention, NYS-12/12-A/12-B/12-C (hereinafter "Consolidated Contention 12-C"), which asserts th at the analysis set forth in the Nuclear Regulatory Commission ("NRC") Staff's December 2010 Final Supplemental Environmental Impact Statement concerning the Severe Accident Mitigation analysis and the inputs to the computer code that were used to evaluate the decontamination and cleanup costs associated with severe accidents, does not meet the requirements of National Environmental Policy Act ("NEPA"), and the regulations implementing NEPA adopted by the NRC and the Council on Environmental Quality. | : 1. I serve as an Assistant A ttorney General for the State of New York, counsel for petitioner-intervenor State of New York in this proceeding. I submit this declaration and accompanying exhibits in support of the Stat e of New York's contention, NYS-12/12-A/12-B/12-C (hereinafter "Consolidated Contention 12-C"), which asserts th at the analysis set forth in the Nuclear Regulatory Commission ("NRC") Staff's December 2010 Final Supplemental Environmental Impact Statement concerning the Severe Accident Mitigation analysis and the inputs to the computer code that were used to evaluate the decontamination and cleanup costs associated with severe accidents, does not meet the requirements of National Environmental Policy Act ("NEPA"), and the regulations implementing NEPA adopted by the NRC and the Council on Environmental Quality. | ||
: 2. The accompanying exhibits are discussed in more detail in the State's Statement of Position, and/or were previously submitted as supporting evidence for the State's contentions. | : 2. The accompanying exhibits are discussed in more detail in the State's Statement of Position, and/or were previously submitted as supporting evidence for the State's contentions. | ||
: 3. Attached to this declaration as Exhib it NYSR70001 is a true and correct copy of the document entitled State of New York Hearing Exhibi ts List ("NYS Exhibits List"), Exh. NYSR70001. | : 3. Attached to this declaration as Exhib it NYSR70001 is a true and correct copy of the document entitled State of New York Hearing Exhibi ts List ("NYS Exhibits List"), Exh. NYSR70001. | ||
NYS Exhibits List includes those exhib its relied upon and refere nced in support of Consolidated Contention 12-C, NYS000240 through NYS000292. | NYS Exhibits List includes those exhib its relied upon and refere nced in support of Consolidated Contention 12-C, NYS000240 through NYS000292. | ||
: 4. Attached to this declaration as Exhi bit NYS000288 is a true and correct copy of the document entitled NUREG/CR-4691, SAND86-1562, Vol. 2, MELCOR Accident Consequence Code System (MACCS) (February 1990). | : 4. Attached to this declaration as Exhi bit NYS000288 is a true and correct copy of the document entitled NUREG/CR-4691, SAND86-1562, Vol. 2, MELCOR Accident Consequence Code System (MACCS) (February 1990). | ||
: 5. Attached to this declaration as Exhi bit NYS000287 is a true and correct copy of the document entitled NEI 05-01 [Rev A], Severe Accident Mitigation Alternatives (SAMA) | : 5. Attached to this declaration as Exhi bit NYS000287 is a true and correct copy of the document entitled NEI 05-01 [Rev A], Severe Accident Mitigation Alternatives (SAMA) | ||
Analysis, Guidance Document (November 2005). | Analysis, Guidance Document (November 2005). | ||
: 6. Attached to this declaration as Exhi bit NYS000286 is a true and correct copy of the document entitled Indian Point: The Next Fukushima?, V. Gilinsky, The New York Times (Dec. 16, 2011). | : 6. Attached to this declaration as Exhi bit NYS000286 is a true and correct copy of the document entitled Indian Point: The Next Fukushima?, V. Gilinsky, The New York Times (Dec. 16, 2011). | ||
: 7. I declare under penalty of perjury that the foregoing is true and correct. | : 7. I declare under penalty of perjury that the foregoing is true and correct. | ||
Executed on December 21, 2011 Signed (electronically) by | Executed on December 21, 2011 Signed (electronically) by | ||
Revision as of 06:53, 30 April 2019
| ML11355A247 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/21/2011 |
| From: | Liberatore K M State of NY, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML11355A240 | List: |
| References | |
| RAS 21598, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML11355A247 (2) | |
Text
- 1 -UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
x In re: Docket Nos. 50-247-LR; 50-286-LR
License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. December 21, 2011
x DECLARATION OF KATHRYN M. LIBERATORE Pursuant to 28 U.S.C. § 1746, Kathryn M. Li beratore hereby declares as follows:
- 1. I serve as an Assistant A ttorney General for the State of New York, counsel for petitioner-intervenor State of New York in this proceeding. I submit this declaration and accompanying exhibits in support of the Stat e of New York's contention, NYS-12/12-A/12-B/12-C (hereinafter "Consolidated Contention 12-C"), which asserts th at the analysis set forth in the Nuclear Regulatory Commission ("NRC") Staff's December 2010 Final Supplemental Environmental Impact Statement concerning the Severe Accident Mitigation analysis and the inputs to the computer code that were used to evaluate the decontamination and cleanup costs associated with severe accidents, does not meet the requirements of National Environmental Policy Act ("NEPA"), and the regulations implementing NEPA adopted by the NRC and the Council on Environmental Quality.
- 2. The accompanying exhibits are discussed in more detail in the State's Statement of Position, and/or were previously submitted as supporting evidence for the State's contentions.
- 3. Attached to this declaration as Exhib it NYSR70001 is a true and correct copy of the document entitled State of New York Hearing Exhibi ts List ("NYS Exhibits List"), Exh. NYSR70001.
NYS Exhibits List includes those exhib its relied upon and refere nced in support of Consolidated Contention 12-C, NYS000240 through NYS000292.
- 4. Attached to this declaration as Exhi bit NYS000288 is a true and correct copy of the document entitled NUREG/CR-4691, SAND86-1562, Vol. 2, MELCOR Accident Consequence Code System (MACCS) (February 1990).
- 5. Attached to this declaration as Exhi bit NYS000287 is a true and correct copy of the document entitled NEI 05-01 [Rev A], Severe Accident Mitigation Alternatives (SAMA)
Analysis, Guidance Document (November 2005).
- 6. Attached to this declaration as Exhi bit NYS000286 is a true and correct copy of the document entitled Indian Point: The Next Fukushima?, V. Gilinsky, The New York Times (Dec. 16, 2011).
- 7. I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 21, 2011 Signed (electronically) by
_______________________
Kathryn M. Liberatore Assistant Attorney General Office of the Attorney General of the State of New York
120 Broadway
(212) 416-8482